Invesco Ltd

Available disclosures provide only limited insight into how Invesco governs climate-related lobbying. The company notes that "Invesco's chief executive officer and the Invesco Ltd. Board of Directors have general supervisory oversight responsibility for the company's activities and policies" and that "Senior Management oversees our day-to-day engagement, including through our cross-functional regulatory change committees," indicating that senior leadership is nominally accountable for policy engagement. However, apart from this high-level statement of oversight, we found no evidence of a defined review, monitoring, or escalation process to ensure lobbying positions are aligned with Invesco's climate strategy, nor any reference to assessing or managing the climate positions of trade associations. The statement that "The Board is responsible for setting, maintaining and regularly reassessing the policies and processes to manage the firm's overall exposure to risk" is broad and does not describe specific mechanisms for lobbying alignment. The company also confirms that it has "No" public commitment "to conduct [its] engagement activities in line with the goals of the Paris Agreement," which further limits transparency on climate-lobbying governance. Overall, disclosure is limited to identifying who holds general oversight, while the procedures, monitoring details, and coverage of indirect lobbying are not disclosed.